Bio

Ryan Dunn has extensive experience in international tax planning for both businesses and individuals. He also provides domestic tax advice to partnerships, corporations, S corporations and their respective owners on various business transactions, including formations, mergers, acquisitions, internal restructurings and divestitures. In his international tax practice, Ryan provides US tax advice to both US businesses with foreign operations and foreign businesses with US operations. These businesses face issues such as whether they should be structured as flow through or corporate entities for US tax purposes and whether their activities in a particular country amount to a permanent establishment under a relevant income tax treaty. Other issues applying to these clients can be the application of US anti-deferral regimes including Subpart F, global intangible low-taxed income ("GILTI"), and passive foreign investment companies ("PFICs"). For individuals, Ryan provides pre-immigration planning advice to foreign persons prior to establishing US tax residency. He also advises US residents on the tax implications of relinquishing US citizenship or terminating lawful permanent residency ("green card") status. Ryan also provides tailored US tax advice to foreigners planning on investing in US real estate by taking into consideration the source country, US tax return filing obligations, US estate and gift tax considerations, planned exit strategy, and other relevant factors.